Health Canada provides guidelines that state that Canadians
should consume no more than 400 to 450 mg of caffeine per day. Also, pregnant women are
often advised by their physicians to limit or eliminate caffeine during their pregnancy
because of a growing body of evidence that suggests that caffeine consumption by women who
are pregnant or might become pregnant increases the risk of delayed conception, fetal
growth retardation, and miscarriage.

In addition to the effects on reproduction, caffeine has
been shown to affect calcium balance and may contribute to decreased bone density and
osteoporosis. While the effect of caffeine on calcium balance may be modest, the impact on
the publics health could be significant in light of the fact that many women do not
consume enough calcium.

Caffeine also can cause behavioural effects, including
anxiety, sleeplessness, addiction, and withdrawal upon cessation of consumption. Those
adverse effects have been reported in children as well as in adults.

In addition, many children consume large quantities of (and
may be addicted to) soft drinks, which are often high in calories and devoid of nutrients,
in place of more nutrient-dense beverages such as fruit juice and milk. According to 1996
consumption data, Canadians drink 25% more soft drinks than milk (110 litres of soft
drinks, 88 litres of milk annually). Eighty percent of the soft drinks consumed were the
heavily sweetened, non-diet variety. In another study, children who consumed one or more
soft drinks a day consumed one-fifth less calcium than children who did not drink soft
drinks.

To give consumers more information to make educated
decisions about caffeine consumption, we urge that Health Canada implement the following
measures.

I. Health Canada should require that caffeine content be
disclosed on food labels.

Caffeine is present in a variety of foods and beverages. It
is found not only in coffee, tea, and colas, but also in ice cream and yogurt. It is
difficult for consumers to predict the caffeine content of many of those foods and
beverages, since the levels of caffeine vary widely between brands. For example, Maxwell
House percolator coffee has 173 mg of caffeine per 236 mL serving while Tasters
Choice has less than half that amount.

Many Canadians are interested in information about the
caffeine content of foods and beverages so that they can manage their intake. Drivers who
wish to stay awake and students studying for exams may rely on caffeine to help them stay
alert. The parents of young children might wish to limit their childrens consumption
of foods containing this stimulant close to bedtime. Pregnant women may wish to choose
products with less caffeine or entirely eliminate caffeine from their diet. Others might
wish to limit their caffeine intake to help prevent such side effects as nervousness,
irritability, or sleeplessness.

Thus, we urge Health Canada to require that foods that
contain significant amounts of caffeine (either naturally or as a food additive) disclose
on the product label the amount of caffeine (in milligrams) per serving.

II. Health Canada should conduct a study about the health
effects of caffeine and determine what other actions should be taken to inform the public
about side effects of caffeine.

Caffeine is the only drug that is widely added to the food
supply. It is consumed by a large proportion of the population. Caffeine is an addictive
stimulant. Scientific research has demonstrated that caffeine consumption affects
reproduction, behaviour, and bone-mineral metabolism and has negative nutritional
consequences for children.

Health Canada should conduct a thorough review of the
effects of caffeine on health and behaviour to determine if further regulatory or
educational actions should be taken to inform consumers about adverse effects associated
with caffeine consumption.

Sincerely,

John Brosnan, Ph.D.
Professor and Head
Department of Biochemistry
Memorial University of Newfoundland

Marvin Gans, M.D.
Associate Professor of Paediatrics
University of Toronto